DEFRA WR1120: BASELINE WORK FOR REVISED ENVIRONMENTAL PERMITTING REGULATIONS: WASTES SPREAD TO LAND WRc Ref: DEFRA8242 MAY 2010 WR1120: BASELINE WORK FOR REVISED ENVIRONMENTAL PERMITTING REGULATIONS: WASTES SPREAD TO LAND WRc Report No.: DEFRA8242 Date: May 2010 Authors: James Peacock, Victoria Benson and Jane Turrell Contract Manager: James Peacock Contract No.: 15419-0 Any enquiries relating to this report should be referred to the authors at the following address: WRc Swindon, Frankland Road, Blagrove, Swindon, Wiltshire, SN5 8YF. Telephone: + 44 (0) 1793 865000 Fax: + 44 (0) 1793 865001 Website: www.wrcplc.co.uk The contents of this document are subject to copyright and all rights are reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted, in any form or by any means electronic, mechanical, photocopying, recording or otherwise, without the prior written consent of the copyright owner. This document has been produced by WRc plc. CONTENTS 1. INTRODUCTION 1 2. METHODOLOGY 3 2.1 2.2 Extracting information Identify risks 3 3 3. RESULTS 5 3.1 3.2 3.3 Assessment of exemption notifications Literature review Risk Scoring 5 6 11 4. CONCLUSIONS 17 REFERENCES 19 APPENDICES APPENDIX A APPENDIX B METHODOLOGY FOR ASSESSING IMPACTS AND PRIORITISING HIGH RISK WASTES DATA SUMMARIES FOR WASTE CATEGORIES 27 33 LIST OF TABLES Table 1.1 Table 3.1 Table 3.2 Table 3.3 Table 3.4 Waste materials to be considered for assessment of environmental impacts Number of exemption notifications available for each waste material Waste materials to be considered for assessment of environmental impacts Waste materials to be considered for assessment of environmental impacts Comparison of risk scores between wastes applied under EPR 2007 Regulations and EPR 2009 Regulations 1 5 12 14 15 Defra 1. INTRODUCTION Waste materials have been applied to agricultural soils for many decades. Waste materials can confer many benefits to agricultural soil, which are principally adding nutrients essential for plant growth, adding organic carbon for improved soil structure, and altering pH of the soil to give optimum growing conditions. Spreading waste to agricultural land has the benefit of diverting waste that would have otherwise be destined for landfill. Although there are obvious benefits of applying waste to land, the activity is not without risk to the environment and human health, it is therefore currently controlled by the Environment Agency under the terms of the Waste Framework Directive (2006/12/EC). Up to April 2010, the majority of wastes applied to land had been carried out under exemption from Environmental Permitting. From April 2010, the Environmental Permitting Regulations 2009 came into force, which introduced substantial changes to the way waste to land is managed. Many of the higher risk wastes are now regulated under standard permits. However, a number of ‘lower risk’ waste materials can still be applied under an exemption. Following work carried out for project WR1103, Defra wished to assess the wastes being spread to land under the revised Environmental Permitting Regulations 2009 (EPR2009) in terms of the risks and benefits in their application to land. The categories of waste materials for consideration are given in Table 1.1. Table 1.1 Waste materials to be considered for assessment of environmental impacts List of wastes code Waste Description 010102, 010408, 170504 Chalk only 020106 Farmyard and horse manure only 020202 Shellfish shells from which the soft tissue or flesh has been removed only 020399, 020401 Soil from cleaning and washing fruit and vegetables only 100101 Ash from wood chip boilers produced pursuant to an operation described in the paragraph numbered U4 in this Chapter only 170506 Dredging spoil (other than those mentioned in 170505) generated from the creation or maintenance of habitats, ditches or ponds within parks, gardens, fields and forests only 020199 Spent compost from the growing of mushrooms only 190599 Compost produced pursuant to a treatment described in the paragraph numbered T23 or T26 of Chapter 2 only 190604 Digestate produced pursuant to a treatment described in the paragraph numbered T24 or T25 of Chapter 2 only WRc Ref: DEFRA8242/15419-0 May 2010 1 Defra List of wastes code Waste Description 190812 Waste consisting of biobed or biofilter material produced pursuant to a treatment described in the paragraph numbered T32 of Chapter 2 only 200108 Coffee grounds only 020199 Milk from agricultural premises only. As with the previous Defra project WR1103, details on the characteristics and loading rates of these waste materials were obtained from notification forms for paragraph 7 exemptions. For this project, notifications for applying waste to land were obtained for the period November 2008 – November 2009, and amalgamated with data collected for project WR1103 (July 2007 – July 2008). This gave two full years worth of data on the application of these materials to land in England and Wales. From the notifications, it would appear that a number of these waste materials are only spread in very small amounts in the UK, and in some cases there are no notifications for the materials to be spread to land under a paragraph 7 exemption. In this report, data on each waste material has been compiled, and ranked against all wastes applied to land under paragraph 7. The general properties of the waste materials are discussed, and data collected from paragraph 7 notification forms and other sources presented. WRc Ref: DEFRA8242/15419-0 May 2010 2 Defra 2. METHODOLOGY 2.1 Extracting information The Environment Agency‘s database was queried using the List of Waste/European Waste Catalogue code in order to obtain notifications specific to the wastes listed. Due to the way the notifications are stored on the system, it was not possible to obtain a detailed description of the waste type being applied for until the above List was obtained. WRc therefore requested from the Environment Agency (EA) all applications with List of Waste (LoW) codes matching those in Table 1.1. As the waste types being investigated were more specific than LoW categories, it was necessary to look at all the application forms for the listed European Waste Catalogue (EWC) codes to identify the sub-set that were required. Once the notifications were obtained from the EA, the following information could be extracted from the notifications: Detailed description of waste being applied. Where it is being applied, including the national grid reference (NGR). Amount of waste being applied, application rate and whether it is being applied in conjunction with any other wastes. Waste characteristics data including (where available) major nutrients, metals, pH, dry matter, organic content and any other trace contaminant/nutrient data. This data was entered into the database generated under the previous Defra project, WR1103. Where insufficient data was available on a specific waste stream, a brief literature review was conducted. This was necessary for a number of waste materials where no information was available from exemption notifications (as discussed in Section 3). The literature was searched for compositional data; information on how the material is spread to land and justifications in terms of agricultural benefit. Table 3.1 shows the number of exemption applications that were available for each waste type. 2.2 Identify risks On completion of the data collection exercise and the literature review, risk scores were derived for each waste material. This was undertaken using the same risk assessment methodology used for the previous Defra project, WR1103. The methodology is reproduced in Appendix A. Once the risk score had been derived, this was then compared with wastes from project WR1103. WRc Ref: DEFRA8242/15419-0 May 2010 3 Defra WRc Ref: DEFRA8242/15419-0 May 2010 4 Defra 3. RESULTS 3.1 Assessment of exemption notifications Table 3.1 lists the number of exemption notifications available for the assessment. Table 3.1 Number of exemption notifications available for each waste material Number of notification forms available Waste material 0 – supplemented with data from Defra project WQ0206 Farmyard and horse manure only Compost produced pursuant to a treatment described in the paragraph numbered T23 or T26 of Chapter 2 only 65 Digestate produced pursuant to a treatment described in the paragraph numbered T24 or T25 of Chapter 2 only 15 Soil from cleaning and washing fruit and vegetables only 34 Spent compost from the growing of mushrooms only 0 Milk from agricultural premises only 18 Chalk only 0 Ash from wood chip boilers produced pursuant to an operation described in the paragraph numbered U4 in this Chapter only 0 Dredging spoil (other than those mentioned in 170505) generated from the creation or maintenance of habitats, ditches or ponds within parks, gardens, fields and forests only 7 Coffee grounds only 11 Shellfish shells from which the soft tissue or flesh has been removed only 0 Waste consisting of biobed or biofilter material produced pursuant to a treatment described in the paragraph numbered T32 of Chapter 2 only* 0* *Biobed material is currently applied to land under a paragraph 16 exemption, where there is no requirement to test waste being applied to land There was no data available from the exemption notifications on manure; mushroom compost; chalk; ash from wood chip boilers; shellfish shells or biobed waste and risk scores were therefore derived from literature review data. This does not conclude that this material is not applied to land for agricultural benefit; the reasons for lack of notification forms are discussed below. General characteristics of each material are also discussed, along with reported agronomic benefits and environmental impacts. WRc Ref: DEFRA8242/15419-0 May 2010 5 Defra 3.2 Literature review 3.2.1 010102, 010408, 170504 Chalk only Chalk can be applied to land where the acidity of soil requires correction. Chalk has a neutralising value (NV) of 50-55% of pure lime (RB209), indicating it would need to be applied at 1.8-2 times the rate of lime to achieve the same change in soil pH. The Fertiliser Handbook (RB209) provides guidance on the amounts of liming material that must be applied to different soil types and different pHs. This guidance should be followed when applying chalk to land. Waste calcium carbonate is produced by the fertiliser industry in the manufacture of ammonium sulphate (Dass, 1993), from quarrying and in cement production. No notifications were found relating to the spreading of waste chalk to agricultural land. This may have been because operators do not consider the chalk a waste material. Waste from mines and quarries only became a controlled waste in 2006 (under The Waste Management (England and Wales) Regulations 2006), and therefore considering implications of waste regulations may be new for many operators. Contamination of chalk will depend on the source, although natural chalk waste should be free of trace metal contaminants. Calcium carbonate generated by the chemical processing industry may contain other contaminants specific to the process from which it was generated. 3.2.2 020106 Farmyard and horse manure only Farmyard and horse manure is not considered a waste material (ECJ Case C-416/02) under the terms of the Waste Framework Directive when used as a soil fertiliser, and there is therefore no need to obtain an exemption from Environmental Permitting. However, an exemption has been maintained as ―Defra cannot exclude the possibility that there may be some circumstances in which manure/slurry is classified as waste either in relation to its storage or its use as a soil fertiliser – i.e. land treatment resulting in benefit to agriculture.‖ This exemption is therefore not widely used, and indeed it was found that very few paragraph 7 exemptions had been registered for this use. Animal manures are principally derived from cattle, poultry, pigs and sheep and are in the form of either liquid slurries or more solid manures. These materials consist of animal faeces and urine mixed with bedding material (typically straw). They are usually rich in readily available N from the urine and have been applied to agricultural land principally as a fertiliser to supply N, P and K. Guidance on the nutrient content and how to apply animal manures is given in Defra‘s Fertiliser Handbook (RB209). The majority of organic matter in manures and slurries is not considered to be highly biodegradable as it comprises material that has already been through a decomposition process in the animal gut. However, a proportion of the carbon in manures is in the form of volatile solids (VS) and these compounds are precursors of emissions of methane (CH 4) and non-methane volatile organic compounds (NMVOCs) and may also be a source of metabolizable carbon for soil microbes. Manures are increasingly being considered as a feedstock for anaerobic digestion which would lead to changes in the characteristics of resulting digestate, in particular the reduction in the proportion of C as VS due to microbial breakdown of VS to CH4. WRc Ref: DEFRA8242/15419-0 May 2010 6 Defra Total livestock manure applied to land in the UK on an annual basis is estimated at 90.7 million tonnes fresh weight (15.7 million tonnes dry weight) (Humphries et al. 2007), compared to 8 million tonnes fresh weight of all waste spread under paragraph 7 exemptions in England and Wales (WRc, 2009). This shows that large amounts of manure are being applied to land outside of the exemption regime. Animal manures do not have the same requirements for treatment prior to application to land as do other animal by-products. Animal manures can be applied to land with minimal treatment, and therefore there is some residual risk of the spread of animal pathogens. It is therefore important to observe good agricultural practice when applying these materials in order to mitigate any potential risk from pathogens. 3.2.3 020199 Spent compost from the growing of mushrooms only Defra have produced a number of papers pertinent to growing media and soil improvers since 1999, including monitoring and assessment of spent mushroom compost as a soil improver [68, 46, 103]. The UN training manual for mushroom growing also includes a section on recycling the spent compost to other applications [65]. Individual papers such as 60, 61, 63, 64 and 66 all look at the benefits of spent mushroom compost for various applications. Paper 66 talks exclusively about spent mushroom compost and its benefits, properties and scientific backing. Mushroom compost can contain many types of manure, gypsum (to raise pH) and may also contain added inorganic nutrients. Mushroom compost also typically contains 15-30% peat. Mushroom compost is likely to contain similar levels of metals to composted manure, as this is the bulk input to the mushroom compost. Levels of nutrients will differ from compost. In some cases nitrogen, phosphate and potassium (NPK) fertilisers are added to the compost before it is sold on to end users. 3 Total supply is estimated to be approximately 280,000 m per year which places spent mushroom compost second to bark as the most significant alternative to peat. The landscaping sector is the largest single user of mushroom compost, accounting for 68% of the total market for spent mushroom compost. Mushroom compost may contain traces of fungicides used to treat fungal competitors to the mushrooms, although it is generally low in other organics as mushrooms are generally intolerant to chemicals. 3.2.4 020202 Shellfish shells from which the soft tissue or flesh has been removed only As an animal by-product, shellfish shells are subject to the Animal By-product Regulations, which specify the treatment requirements for the material prior to being applied to land, to remove any pathogens present in the waste. Shellfish shells have a high proportion of CaCO 3, and indeed have a very similar liming potential to pure CaCO3 [109]. One potential obstacle is the residual salt (NaCl) contamination on the shells, which may affect some crops, but is unlikely to leach to controlled waters in sufficient concentrations to cause pollution. Similar controls are placed on shellfish shells as are currently applied to general fish waste. WRc Ref: DEFRA8242/15419-0 May 2010 7 Defra SEAFISH appear to have undertaken the majority of the research into land-spreading shellfish waste. A report by Defra [30] describes the overall impact of the fish and shellfish industry including a lifecycle assessment but it does not contain much information on disposal options. ADAS undertook a study for SEAFISH [31] which looked at the disposal and treatment options for waste shellfish including the agricultural benefit and composition of the waste applied to land. Shellfish cannot be applied to land without pre-treatment; composting, anaerobic digestion and rendering are the predominant forms of treatment (SEAFISH [27, 29, 51]). The autoclaving guidance from SEAFISH [27] reports that it is difficult to sufficiently clean shellfish shells for other notifications and this means most shellfish waste is primarily dealt with whole (i.e. with residual organic matter still attached). Further information on the composting of waste has been developed by the Compost Council of Canada Symposium and the Irish Sea Fisheries Board [25, 28]. 3.2.5 020399, 020401 Soil from cleaning and washing fruit and vegetables only A large amount of soil from cleaning and washing of fruit and vegetables is applied to land under paragraph 7 exemptions. The soil is commonly separated from wash water by a dissolved air flotation (DAF) system or similar prior to being applied to land. Another common practice is that the soil is applied with vegetable peelings which may be mixed during the preparation process or subsequent to the water treatment. Waste soil mixed with vegetable peelings was not included in the assessment and it may be difficult to separate these wastes where they are produced as part of the process. The soils may contain residues of pesticides and fertilisers that have been applied to the crops. However, where these are dissolved they will generally be removed during the DAF process. Soil from cleaning and washing fruit and vegetables alone is often included under ―vegetable processing waste‖ as in papers 82, 71 and 72. Imperial College (2006) undertook a study into the application of industrial biowastes to land and looked at the composition of potato washwater. 3.2.6 100101 Ash from wood chip boilers Ash from wood chip boilers will generally have low trace metal contaminants, but this is dependent on the quality control of the input material. Organic compounds will obviously be lost in the incineration process, and ash will therefore have almost zero biodegradability potential. Ash will generally have an alkali pH (pH 10 – 12.5), and have some liming potential for treatment of acidic soils. As any pathogens present in the feedstock would be destroyed in the incineration process, pathogen potential will be extremely low, and therefore low risk. Wood may be treated with copper chromium arsenic (CCA) treatments, but this use has been limited since 2003 (WRAP, 2005). Arsenic is a volatile metal so it will mostly be lost in the incineration process, but a portion will remain in the ash. Copper and chromium will predominantly remain in the ash. However, CCA and creosote treated wood is classified as hazardous waste, and should not be burnt in a standard wood chip boiler. Wood can also be treated with a range of organic chemicals, but these will be lost to the atmosphere in the incineration process. WRc Ref: DEFRA8242/15419-0 May 2010 8 Defra An EU Life project [70] looked at the recycling of wood chip boiler ash to forest communities and demonstrated the agronomic, economic and environmental benefits of recycling ash to woodland soils. These can be treated and turned into pellets etc. Work has also been done by the Nordic Innovation Centre along the same lines as the EU Life project [75] with greater emphasis on the physical and chemical properties of the ash and included its use in agriculture. The lower limit for application of ash is one tonne per hectare. This very low application rate will help to mitigate any risk from metals present in the ash. 3.2.7 170506 Dredging spoil (other than those mentioned in 170505) Dredging spoil is applied in large amounts to agricultural soil in the UK. In the original WRc report (WR1103) it was found that dredging materials were one of the higher risk materials applied to land, generally due to the very large quantities at which they are applied 1. Dredgings are also very variable materials, and are likely to contain larger quantities of contaminants downstream of settlements where a large number of industrial effluents are discharged into the watercourse. A small number of notifications were made for dredgings, particularly from park and garden ponds and lakes. These appear to have lower levels of heavy metals than dredgings taken from waterways in industrial areas. However, no information on organic contaminants in the dredgings could be found. Certain potential organic pollutants (POPs) with toxic effects such as poly-aromatic hydrocarbons (PAHs) have a high affinity for organic rich fines in sediments, so where there is potential contamination of the water from which the dredgings are taken, these may accumulate in the sediments. However, this does not appear to be a subject that has been studied extensively, and analysis of POPs is not required for application under a paragraph 7 exemption. Most of the literature concerning dredging spoil application to land focuses on the effects of marine sediments to land. The National Trust produced a report resulting from a workshop on sediment management and dredging of lakes [54] in which they discuss spreading the dredgings to land and the Broads Authority produced a paper on strategic dredging and disposal sites [57]. Other than this, there is very little to be found on the disposal of dredging spoil from inland conservation practices. Daniels et al [53] Aweto et al [55] and Babinchak et al [56] all produced papers on certain effects of dredging spoil on agricultural land but these are all applications outside the UK and Europe. 3.2.8 190599 Compost produced pursuant to a treatment described in the paragraph numbered T23 or T26 of Chapter 2 only The exemptions database holds a large amount of data for composting as it is widely spread to land in the UK under paragraph 7 exemptions. Compost that meets the PAS100 quality standard is no longer considered a waste and there is therefore no requirement to register a paragraph 7 exemption in order to apply it to land. Compost applied to land under a paragraph 7 exemption is therefore non-PAS100 compost. 1 Under paragraph 7 exemption, dredging spoil may be applied at 1250 tonnes per hectare, whereas most other materials are limited to 250 tonnes per hectare. WRc Ref: DEFRA8242/15419-0 May 2010 9 Defra In 2003, WRAP commissioned a literature review (Jones and Martin 2003) on human and animal pathogens from green waste compost. This review found that composting at a temperature of 55oC for at least 3 days was sufficient to eradicate most pathogens. Pathogens are therefore considered low risk in composts from green wastes. In any case, composting will reduce the risk of pathogens over the input material. Human and animal pathogens from other materials may present a risk, for example animal tissue waste, materials unsuitable for consumption or processing and kitchen waste. However, as this material is subject to the Animal By-product Regulations, this should be sufficient to negate any pathogen risk. The nitrogen content of compost tends to be independent of the input material, as substances with high nitrogen content will be broken down during the composting process. Applications may be limited by NVZ limits (250 kg/ha) before the limit for the exemption is reached (50 tonnes per hectare). In addition, Defra has undertaken a review of the environmental and human health effects of some waste management processes, which included the composting of green and kitchen waste [39]. Monitoring and assessment papers were produced for growing media and soil improvers [68, 46, 103], which include green waste compost. The ADAS project [84] on application of compost and fertility of soil also holds information on the application and effect of compost on soil. A paper on the merits, composition and application for vermicompost (produced from a wormery) versus compost [62], showed the two substances had very similar nutrient and trace metal compositions. 3.2.9 200108 Coffee grounds only Coffee grounds contain nitrogen, principally in an organic form, not available to plants until it has been broken down. Total N is less than 10 000 (about the equivalent of compost) and phosphorus and potassium. Coffee grounds contain very low levels of trace metals, and would therefore not be considered a risk from this point of view. No information was found on pathogen risk, but it is considered that the risk is low. There is very little information in the scientific literature on land spreading of coffee grounds. At present, it is practiced on an industrial scale in the UK but not widespread across the country. 3.2.10 020199 Milk from agricultural premises only Application of waste milk to land is common under paragraph 7 exemptions. Milk must be applied in a diluted form as it carries a very high biological oxygen demand (BOD) which can have large environmental consequences to organisms in surface water. Application of milk must therefore be carefully managed. Milk will contain very low levels of metals, and limited amounts of nitrogen and phosphorus, but may add trace nutrients. Bacteria in unpasteurised milk may benefit soil microbial populations. WRc Ref: DEFRA8242/15419-0 May 2010 10 Defra 3.3 Risk scoring Following assessment of data from exemption notifications and the literature review, the waste materials can be scored using the scoring mechanism as used in project WR1103. The wastes can then be ranked alongside other waste materials to show their relative risk. The full scoring mechanism is reproduced in Appendix A. The risk score takes into account the following factors: Total amount of waste material spread nationally; The total loading rate (tonnes per hectare) of the waste; Nutrient content (principally nitrogen and phosphorus); Heavy metal content; Assessment of risk of microbial pathogens, organic pollutants and biodegradability (and hence greenhouse gas emissions) of the waste. For some of the wastes on certain parameters, estimates had to be made as it was not possible to obtain information on the waste materials from paragraph 7 exemption notifications as the materials are not applied under paragraph 7. In particular, the total amount of the waste spread nationally is not known in many cases. The amount of waste spread per hectare has been fixed at an application rate limit set in the exemption (50 t/ha for the majority of wastes). In many cases, it is likely that smaller amounts of waste will be used, especially where limited by NVZ limits. The overall application of metals and nutrients is given in Table 3.2. It can be seen that the concentrations of metals applied at this loading rate are very low for the majority of the wastes. Generally nitrogen will be applied at less than the maximum rate allowable under the nitrogen vulnerable zones legislation of 250 kg/ha, with the exception of coffee grounds, compost and manures. It should be noted, however, that the figure for manures is a percentile value based on a number of readings for manures and slurries from a number of different animals, and total nitrogen concentration will vary considerably depending on the exact source. Defra‘s Fertiliser Handbook (RB209) gives guidance on how these materials should be applied and average nutrient values for different types of manure. Using the full assessment methodology given in Appendix A, scores were derived using the categories outlines above. Each category was given a score weighting, and Table 3.3 gives the overall scores from this exercise. These scores were compared to scores given previously in the earlier project (WR1103) which are outlined in Table 3.4. WRc Ref: DEFRA8242/15419-0 May 2010 11 Defra Table 3.2 Waste materials to be considered for assessment of environmental impacts Waste material EWC Total waste Waste per spread (t hectare 000s) (t/ha) Zn kg/ha Cu kg/ha Ni kg/ha Pb kg/ha Cd kg/ha Cr kg/ha Hg kg/ha N (kg/ha) P (kg/ha) Microbial pathogen risk Organic pollutant Biodegradability 010102, Chalk only Unknown 50 low low low low low low low low low N N N 15 700 50 11 3.7 0.35 0.16 0.02 0.32 - 448 154 Y N Y 50 low low low low low low low low low Y N N 50 1.55 0.29 0.23 0.05 0.03 0.25 0.01 50 9 N N N 100101 1 - - - - - - - low v low N N N 170506 100 56 7.91 2.88 4.98 0.07 0.97 0.01 229 105 Y N Y 010408, 170504 Farmyard and horse manure only 020106 Shellfish shells from which the soft tissue or flesh has been 020202 removed only Soil from cleaning and washing fruit and vegetables only 020399, 020401 Ash from wood chip boilers produced pursuant to an operation described in the paragraph numbered U4 in this Chapter only Dredging spoil (other than those mentioned in 170505) generated from the creation or maintenance of habitats, ditches or ponds within parks, gardens, fields and forests only WRc Ref: DEFRA8242/15419-0 May 2010 12 Defra Waste material EWC Total waste Waste per spread (t hectare 000s) (t/ha) Spent compost from Zn kg/ha Cu kg/ha Ni kg/ha Pb kg/ha Cd kg/ha Cr kg/ha Hg kg/ha N (kg/ha) P (kg/ha) Microbial pathogen risk Organic pollutant Biodegradability 020199 50 see compost see compost see compost see compost see compost see compost see compost - - N N Y 190599 50 7.6 3.1 1.2 3.9 0.03 1.0 0.007 295 94 N N N 190604 50 0.293 0.1125 0.0189 0.103 0.0004 0.019 0.0001 364 12.9 N N Y pursuant to a treatment 190812 50 - - - - - - - - - N Y Y 200108 50 1.0 0.84 0.6 0.16 0.007 0.22 0.002 346 91.8 N N Y 020199 0.22 0.40 0.43 0.03 0.03 0.03 0.0033 30 27 0.22 Y N Y the growing of mushrooms only Compost produced pursuant to a treatment described in the paragraph numbered T23 or T26 of Chapter 2 only Digestate produced pursuant to a treatment described in the paragraph numbered T24 or T25 of Chapter 2 only Waste consisting of biobed or biofilter material produced described in the paragraph numbered T32 of Chapter 2 only Coffee grounds only Milk from agricultural premises only. th All concentrations are based on 90 percentiles for each individual waste category. WRc Ref: DEFRA8242/15419-0 May 2010 13 Defra Table 3.3 Waste materials to be considered for assessment of environmental impacts Risk Score Risk rank (out of 85 wastes) Farmyard and horse manure only 1.9 =30 Compost produced pursuant to a treatment described in the paragraph numbered T23 or T26 of Chapter 2 only 1.9 =30 Digestate produced pursuant to a treatment described in the paragraph numbered T24 or T25 of Chapter 2 only 1.9 =30 Soil from cleaning vegetables only 1.5 =34 Spent compost from the growing of mushrooms only* 1.5 =34 Milk from agricultural premises only 1.5 =34 Chalk only* 1.0 =41 Ash from wood chip boilers produced pursuant to an operation described in the paragraph numbered U4 in this Chapter only* 1.0 =41 Dredging spoil (other than those mentioned in 170505) generated from the creation or maintenance of habitats, ditches or ponds within parks, gardens, fields and forests only 1.0 =41 Coffee grounds only 0.6 55 Shellfish shells from which the soft tissue or flesh has been removed only* 0.5 =58 Waste consisting of biobed or biofilter material produced pursuant to a treatment described in the paragraph numbered T32 of Chapter 2 only* 0.5 =58 Waste material and washing fruit and The waste materials marked with an asterisk (*) did not have any registered notifications for application of the material to land under a paragraph 7 exemption over 24 months (June 2007 – June 2009). For these waste materials, a literature review was carried out to assess potential risks of application to land. The lowest possible score using this scoring mechanism is 0.5. The higher scores are generally due to a larger amount of the waste being spread in larger quantities nationwide (>50 000 tonnes), as the risk assessment methodology gives a high weighting to wastes that WRc Ref: DEFRA8242/15419-0 May 2010 14 Defra are applied in large quantities. If this were discounted, all the waste materials would have a risk score of <0.6. Table 3.4 compares the change in scores between where waste was assessed for this project and where they were assessed previously for project WR1103 (Defra, 2008). Table 3.4 Comparison of risk scores between wastes applied under EPR 2007 Regulations and EPR 2009 Regulations Risk score LoW/EWC code Wastes exempt under EPR 2007 Regs (WR1103) Wastes exempt under EPR 2009 Regs (WR1120) 170506 7.0 1.0 170504 4.5 1.0 020399 3.8 1.5 190599 2.9 1.9 020202 2.0 0.5 190604 1.0 1.9 020106 0.8 1.9 The data shows that for the majority of wastes, the total risk score has been substantially reduced. This is mainly due to more specific definitions given in the Environment Protection Regulations 2009 (EPR2009), which has removed higher risk material from the categories e.g. dredgings are now only included for lakes and ponds; dredgings from canals and rivers are prohibited under the EPR2009. There are inherent problems associated with making a direct comparison of the risk scores attributed to each waste using the two aforementioned regulatory regimes. For example, in this study (under EPR2009), digestates were recorded under LoW codes 19 06 04; 19 06 06; 03 03 05 and 19 06 99. In project WR1103, all waste categories were considered in terms of their LoW code assigned by the applicant. WRc considered all wastes described as 'anaerobic digestates' for this study rather than limiting to only those which were registered under 19 06 04, and therefore the categories are not completely analogous. Risk scores for wastes 19 06 04 (anaerobic digestate) and 02 01 06 actually increased compared with the previous study. For 19 06 04, more waste codes were considered than just 19 06 04, which affected the overall waste applied to land. It should be noted however that all risk scores were still very low. A key factor used within the scoring mechanism is the loading rates of the material in terms of the tonnes per hectare (t/ha) applied to land. As the loading rate increases, so the loading of nutrients and metals will increase, as do the potential risks. In the revised exemption regime for low risk wastes, the maximum total application rate for the waste is limited to 50 t/ha, with the exception of dredging materials and ash which are 100 t/ha and 1 t/ha respectively. Previously, the loading rate of material had been limited to 250 t/ha for WRc Ref: DEFRA8242/15419-0 May 2010 15 Defra most wastes (although higher rates were allowed for dredging materials). This has the effect that lower risk scores are obtained when considering the waste materials spread at lower concentrations. Another factor considered in the overall waste risk score is the total amount of waste spread in England and Wales. The total amount of waste spread was either estimated from data gathered in project WR1103, or taken from literature. As a large multiplier is used for the total amount of waste applied score, this can have a major effect on the final waste score. In addition, as some of the categories have changed slightly, this score will be altered from the previous scores for project WR1103. The limit given in the exemption is 50 t/ha for the material applied to land. In reality, limits from the nitrogen vulnerable zones will limit the application of wastes before 50 t/ha could be applied. For example, application of farm yard manures will often be limited on the basis of their nitrogen content, and will not be applied at the rate of 50 t/ha. WRc Ref: DEFRA8242/15419-0 May 2010 16 Defra 4. CONCLUSIONS The risks of applying the specified materials to land is considered to be low. All materials were scored in the lower half of the list when ranked against all wastes being applied to land. A number of the waste materials do have the potential to have elevated levels of some metals. However, it is considered that the lower maximum limit of loading rate (tonnes per hectare of waste spread) will mitigate these risks when the materials are applied to land. Total nitrogen concentrations in these waste materials do have the potential to exceed nitrogen vulnerable zone (NVZ) limits (250 kg/ha/y) where the materials are applied at the maximum allowable loading rate of 50 tonnes per hectare. Total nitrogen concentration would need to be monitored to avoid exceedances in accordance with good agricultural practice, and may well limit application rates for materials with high nitrogen content. The assessment was carried out using the 90th percentile chemical composition data for each waste category. A high level of variability was seen for most wastes in the parameters for which data was available. This was generally an artefact of the dry solids content of the waste within a specific category. For example, farmyard manure can encompass manures and slurries from a variety of different livestock and these differing materials would account for a great deal of the observed variability. When we compare the waste materials reviewed in this study with those considered previously under project WR1103, most materials produce lower risk scores due to the more limited types of waste allowed in each category. The lower scores were also in part due to the lower application rate limit under the Environmental Permitting Regulations 2010 of 50 t/ha, where under the previous exemption regime it had been 250 t/ha. 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WRc Ref: DEFRA8242/15419-0 May 2010 25 Defra WRc Ref: DEFRA8242/15419-0 May 2010 26 Defra APPENDIX A METHODOLOGY FOR ASSESSING IMPACTS AND PRIORITISING HIGH RISK WASTES INTRODUCTION Identifying high risk wastes by assessing their environmental impact is a key step in the assessment of impact of waste spread to land under paragraph 7 exemptions from Environmental Permitting. To categorise waste types by their overall risk presented for each waste type, a methodology has been developed to attribute a risk score to each waste, allowing comparison of waste types. In order to fully characterise the risk presented from each waste, the two main factors which must be considered are: Amount of waste spread (total and amount per hectare) - the total amount spread of any waste in England and Wales, and the average loading per hectare. Properties of the waste – Characteristics of the waste, broken down in to the following six categories: Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg) Nutrient content (N and P) Biodegradability/ C:N ratio (Greenhouse gas potential) Pathogen potential Organic pollutants Reported pollution incidents relating to waste type. As detailed below, a score will be derived for both the amount of waste spread and the properties of the waste, and turned into multiplying factors to obtain the overall risk score. This assessment is a first-pass assessment and necessarily does not take into account every possible characteristic of the waste, and is, in part, qualitative. As such, we will examine the data in more detail for each waste before a final priority list is decided upon. METHODOLOGY The overall risk for each waste is given by the following calculation. Overall risk = Waste properties risk score x Waste spread risk score Where: Waste spread risk score = Total waste score x waste per hectare score Waste properties risk score = Z x Y x X x W x V x U Where Z to V are equal to either 1.0 or 1.25: WRc Ref: DEFRA8242/15419-0 May 2010 27 Defra Z = Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg) Y = Nutrient content (N and P) X = Biodegradability/ C:N ratio (Greenhouse gas potential) W = Pathogen potential U = Organic pollutants V = Reported pollution incidents relating to waste type And Z to U = 1.25 or 1 The calculation is explained further over the following sections. Waste spread risk score Total waste score The total amount of each waste type spread to land is considered to be the most important factor when considering overall environmental risk of the waste. We therefore propose to weight it accordingly, with the highest multiplying factors of any category. Each waste will be given a score of 1 – 3 as follows: Mass spread (t) 0 – 10 000 10 001 – 50 000 >50 000 Score 1 2 3 The mass spread figure is the sum in tonnes of each waste type spread per year. Waste per hectare score The average loading per hectare is also key in terms of environmental risk. The wastes will be divided in to three categories depending on the average amount spread per hectare, and scored as follows: Mass spread (t/h) 0 - 100 101 - 200 >201 Score 0.5 1 1.5 The total waste score and the waste per hectare score are then multiplied together to give a waste spread risk score. WRc Ref: DEFRA8242/15419-0 May 2010 28 Defra Waste properties risk score The six waste properties will also be considered as part of the assessment. To simplify the calculations as far as possible, each waste is placed in one of two risk groups: Low risk (score: 1) High risk (score: 1.25) The multiplying factor for each category are then multiplied together, to produce the over waste properties risk score. Heavy metal content The six metals for which analysis is required as part of an application for a paragraph 7 exemption are: Zinc Lead Cadmium Nickel Mercury Copper Concentration of these metals will form the basis of the calculation for metals contents, which will be obtained from paragraph 7 application forms. We have chosen to compare levels of metals to threshold values set in the compost standard BSI PAS100:2005 levels. These limits were chosen as they are absolute limits, and were set in order to protect human health and the environment when compost is applied to land. The PAS100 limits are as follows: Metal Threshold Value (mg/kg DM) Zinc 400 Lead 200 Cadmium 1.5 Nickel 50 Mercury 1.0 Copper 200 The 90th percentile of metal concentrations for the dataset for each waste will be determined. This will give an indication of the range of data, while discounting any outliers. Where the amount of metal present in the waste is less than the threshold value, it will be given a score of zero. Where the concentration is greater than the threshold value, a score will be given based on the calculation of the ratio - concentration: threshold value. For example, for a waste that has a Zn concentration of 600 mg/kg DM, the score for Zn will be 1.5. WRc Ref: DEFRA8242/15419-0 May 2010 29 Defra This calculation is repeated for each metal to give an overall metals score: Zn score + Pb score + Cd score + Ni score + Hg score + Cu score = overall metals score Where the overall metals score is <3, the waste will be considered low risk with respect to metals and given a multiplying factor of x1. Where the score is >3 it will be considered there is some degree of risk, and a multiplying factor of x1.25 applied. This will identify where individual metals have a high concentration, or where there are a range of metals with slightly elevated concentrations. Nutrients A similar approach will be taken for scoring the nutrient quantity in each waste to the approach it is used for. Nitrogen and phosphate will be considered in the assessment of nutrient content, and will be compared against 5% levels of both nitrogen and phosphorus. Again, where N and P are present below these threshold levels, a score of 0 will be given, and where it is over, a score equal to the ratio of concentration {nutrient: threshold value} will be given, and the two scores from N and P summed: N score (where N > 5% DM) + P score (where P > 5% DM) = overall nutrients score. Where the overall nutrients score is >1.5, a multiplying factor of x1.25 will be applied. Where the overall nutrients score is <1.5, the multiplying factor will be x1. Microbial pathogens, organic pollutants and biodegradability (greenhouse gas potential) The above three categories are grouped together as there is very little data available from the literature, and it is expected that little data will be available from the application forms. The initial review of paragraph 7 application forms has similarly shown very few operators have provided data of this type of analysis. An approach similar to that above will be taken where wastes which have a perceived risk in relation to these categories will be given a multiplying factor of x1.25, and those with a smaller risk will be given a multiplying factor of x1. The process of applying these multiplying factors will necessarily be subjective due to the lack of available data for waste materials. Pollution incidents The number of pollution incidents reported to the Environment Agency for any particular waste stream will be obtained from Environment Agency systems. We will then score the incidents for each waste as follows: Non-serious incident (CICS category 3 or 4) = 1 point Serious incident (CICS category 1 or2) = 3 points The total number of points for each waste will then be summed. If the total points score for any particular waste is greater than 3, it will be given a multiplying factor of x1.25 and if it is less than 3, a multiplying factor of x1 will be applied. WRc Ref: DEFRA8242/15419-0 May 2010 30 Defra FINAL SCORING Following determination of the multiplying factor for each category, these are applied to the waste scores and the overall risk score is determined. A spreadsheet tool has been developed to obtain the score for each waste once the subjective risk assessment has been carried out. Criteria for each category is summarised below. Waste properties Waste spread Group Category Multiplying factor Criteria Total tonnes spread in England and Wales Grouped in to <10 000 t/y (x1), 10 000 – 50 000 (x2) or >50 000 (x3) Based on total waste spread for each waste Average loading rate (t h-1) Grouped in to <100 t/ha (x0.5), 100 – 200 t/h (x1), >200 t/h (x1.5) Based on average loading rate Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg) Score <3 (x1) or score >3 (x1.25) Individual metal concentrations divided by respective PAS100 limits. Where ratio >1, ratios are summed to give overall score. Nutrient content (N and P) Score <1.5 (x1) or >1.5 (x1.25) N and P concentration for each waste divided by 5%. Where this ratio >1, ratios are summed Biodegradability/ C:N ratio (Greenhouse gas potential) No risk (x1) or Some risk (x1.25) Qualitative assessment Pathogen potential No risk (x1) or Some risk (x1.25) Qualitative assessment Organic pollutants No risk (x1) or Some risk (x1.25) Qualitative assessment Reported pollution incidents relating to waste type Score <3 (x1) or score >3 (x1.25) Where serious pollution incident reported score 2, non-serious = 1. Scores are summed for each waste WRc Ref: DEFRA8242/15419-0 May 2010 31 Defra WRc Ref: DEFRA8242/15419-0 May 2010 32 Defra APPENDIX B DATA SUMMARIES FOR WASTE CATEGORIES General process category FYM Compost Dredgings Veg washings Parameter Zn as applied (wet Cu as applied (wet Ni as applied (wet Pb as applied (wet Cd as applied (wet Cr as applied (wet Hg as applied (wet weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg Total N as Total P as applied (wet applied (wet weight) mg/kg weight) mg/kg Minimum 0.8 0.2 0.02 0.01 0.0007 0.01 - 8.4 40 10th Percentile 0.8 0.2 0.02 0.02 0.0013 0.01 - 18 55 Mean 4.1 1.5 0.13 0.07 0.01 0.15 - 218 104 Median 1.7 0.8 0.1 0.0 0.0 0.0 - 146 103 90th Percentile 11 3.7 0.35 0.16 0.02 0.32 - 448 154 Standard deviation 4.1 1.6 0.2 0.1 0.0 0.3 - 225 55 Maximum 11 5.5 0.6 0.2 0.0 1.3 - 851 171 n 16 17 16 16 16 16 - 19 4.0 Minimum 0.008050 0.004500 0.004750 0.001400 0.000250 0.011350 0.000478 0.1 0.01 10th Percentile 1 0.5 0.3 0.075 0.005 0.2 0.0021 56 1.58 Mean 7 2 1 11 0.020 0.8 0.0058 348 47 Median 4 2 1 2 0.016 0.7 0.0043 381 46 90th Percentile 20 3.52 1.27 45 0.04 1.62 0.01 563 93 Standard deviation 8 2 0.50 20 0.01 0.55 0.01 186 38 Maximum 33 14 3 76 0.05 1.85 0.03 645 174 n 63 64 55 56 55 50 55 67 75 Minimum 3.1 2.0 0.9 0.9 0.02 0.61 0.00 132 36 10th Percentile 4.1 2.5 0.9 1.3 0.02 0.62 0.00 143 44 Mean 25 5.2 1.8 3.1 0.04 0.77 0.01 186 75 Median 12 5 1 3 0.04 0.64 0.01 186 75 90th Percentile 56 7.91 2.88 4.98 0.07 0.97 0.01 229 105 Standard deviation 33 3 1 2 0 0 0 77 54 Maximum 73 9 3 6 0 1 0 240 113 n 4 3 3 4 4 3 4 2 2 Minimum 0.01 0.00 0.00050 0.00050 0.00025 0.00050 0.0000500 0.40 0.38 10th Percentile 0.01 0.00 0.005 0.001 0.000250 0.002 0.000060 1 0.5 Mean 0.37 0.11 0.13 0.020 0.009 0.07 0.0020 21 2.8 Median 0.03 0.03 0.05 0.013 0.005 0.03 0.0013 12 1.4 90th Percentile 1.55 0.29 0.23 0.05 0.03 0.25 0.01 50 9 Standard deviation 0.7 0.2 0.3 0.0 0.0 0.1 0.0 27 3 Maximum 2.5 0.5 1.0 0.1 0.1 0.3 0.0 109 12 n 46 46 43 37 34 38 23 46 45 WRc Ref: DEFRA8242/15419-0 May 2010 33 Defra General process category AD Coffee Milk Parameter Zn as applied (wet Cu as applied (wet Ni as applied (wet Pb as applied (wet Cd as applied (wet Cr as applied (wet Hg as applied (wet weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg weight) mg/kg Total N as Total P as applied (wet applied (wet weight) mg/kg weight) mg/kg Minimum 0.22 0.08 0.0098 0.00240 0.00015 0.00640 0.00005 77 3.0 10th Percentile 0.22 0.08 0.010 0.00 0.00015 0.01 0.00005 235 3.0 Mean 0.24 0.10 0.012 0.03 0.00020 0.01 0.00009 303 8.3 Median 0.22 0.11 0.010 0.00 0.00015 0.01 0.00010 304 8.0 90th Percentile 0.29 0.11 0.019 0.10 0.00035 0.02 0.00010 364 13 Standard deviation 0.0 0.02 0.004 0.05 0.00009 0.01 0.00002 64 3.1 Maximum 0.3 0.11 0.02 0.10 0.00035 0.02 0.00010 364 13 n 8 8 8 8 8 8 8 23 23 Minimum 0.43 0.30 0.15 0.01 0.0008 0.08 0.0006 285 39 10th Percentile 0.43 0.30 0.15 0.01 0.0008 0.08 0.0006 285 39 Mean 0.48 0.32 0.42 0.03 0.0016 0.11 0.0007 322 40 Median 0.51 0.30 0.60 0.01 0.0008 0.14 0.0006 347 40 90th Percentile 0.51 0.36 0.60 0.07 0.0030 0.14 0.0010 347 40 Standard deviation 0.0 0.0 0.2 0.0 0.0 0.0 0.00024 34 0.2 Maximum 0.5 0.4 0.6 0.1 0.0 0.1 0.00099 347 40 n 5 5 5 5 5 5 5 5 5 Minimum 0.0003 0.0003 0.0007 0.0003 0.00003 0.0019 0.00001 7.0000 0.4 10th Percentile 0.0003 0.0003 0.0039 0.0003 0.0000 0.0035 0.00001 8.5 0.4 Mean 0.10 0.10 0.10 0.01 0.01 0.02 0.0016 21 7.6 Median 0.10 0.01 0.02 0.0039 0.0003 0.03 0.0013 16 4.2 90th Percentile 0.22 0.40 0.43 0.03 0.03 0.03 0.0033 30 27 Standard deviation 0.10 0.14 0.15 0.02 0.02 0.01 0.0014 11 8 Maximum 0.35 0.40 0.43 0.05 0.05 0.05 0.01 53 27 n 21 20 19 20 19 20 18 22 21 WRc Ref: DEFRA8242/15419-0 May 2010 34